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#2267547 - 03/11/22 07:29 PM Risk Assessment
Jennifer Offline
100 Club
Joined: Dec 2014
Posts: 182
Do you include balances of deposits and loans in your BSA/AML Risk Assessment? If so - why? What risk points?

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#2267555 - 03/11/22 08:40 PM Re: Risk Assessment Jennifer
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 633
No, we have never included any balances of deposits or loans in our BSA/AML Risk Assessment.
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

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#2267583 - 03/13/22 08:23 PM Re: Risk Assessment Jennifer
edAudit Offline
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Joined: Jul 2008
Posts: 4,783
You are here
Yes, in an effort to make the risk assessment quantified. There should also be some determination of why the balances are considered high, medium and low for each category. It may be helpful to detail the balances and number of accounts in each product line.

This would be dependent on your regulator expectations. In NY (downstate) it would be considered a must have.
Opinions can be considered as coming from anywhere but my employer.


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#2267596 - 03/14/22 03:50 PM Re: Risk Assessment Jennifer
Curious in Kansas Offline
Joined: Oct 2015
Posts: 71
No. I've included in my BSA risk assessment a three year historical on the quantity of SARs and CTRs filed along with how many customers have been exempted. Nothing about account balances.

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#2267600 - 03/14/22 04:13 PM Re: Risk Assessment Jennifer
Local_Banker Offline
Joined: Jun 2019
Posts: 55
Yes, I track deposit and loan balances, along with YOY changes. It can highlight any overall growth in your FI as a whole, or highlight any new products/services that you may want to be aware of.

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#2267657 - 03/15/22 03:32 PM Re: Risk Assessment Jennifer
P*Q Offline

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Joined: May 2001
Posts: 8,458
We detail products offered but not balances associated with them.

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#2267719 - 03/16/22 01:55 PM Re: Risk Assessment Jennifer
Goldrose Online
Joined: Sep 2018
Posts: 63
We do include total balance of Loans, Checking accounts and savings accounts at year end, as well as number of customers and how many accounts are business vs personal. These are just part of the numbers we provide, which I will state is on a separate "stats" page, that has our opening summary of the current state of the bank, leadership, number of branches, asset size etc...
Last edited by Goldrose; 03/16/22 01:57 PM.
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#2273315 - 07/23/22 09:58 PM Re: Risk Assessment Jennifer
AML360 Offline
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Joined: Mar 2018
Posts: 5
The volume and value of deposits and loans are relevant to the nature, size and complexity of a bank. This information should be included in the BSA/AML risk assessment. Each product should also be individually assessed.

The remainder of this message has been edited as it was an ad. On BOL, advertisers must contact Tobi Chunowitz to advertise
Last edited by Andy_Z; 07/24/22 02:19 PM.
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#2273816 - 08/04/22 07:42 PM Re: Risk Assessment Jennifer
Questioner Offline
100 Club
Joined: Jan 2012
Posts: 113
Did include the balances of deposits and loans in our BSA/Risk RA. I have a question. We used to outsource the BSA/AML RA and the vendor used to include 4 years worth of historical data comparisons. I think 4 years of stats may a bit too much. How many years of historical data do you normally included for the year-over-year comparisons?
Last edited by Questioner; 08/04/22 07:45 PM.
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